API Spec Q1 Ed 9 & API spec Q2 Ed 1, emphasizes the importance of managing the risks related to facilities, equipment, materials, non-conformities, suppliers and personnel. So let’s explore the concept of risk management more fully, and review some composite factors that have been identified in past incidents:

1. Lack of Commitment - Management sets the tone and culture of an organization, and there is a strong correlation between the level of managerial commitment and corresponding incident rates.

2. Flawed Management of Change - A large percentage of incidents take place after changes to a process or procedure. Implementing an effective Management of Change procedure and, more importantly, evaluating those efforts can dramatically reduce incident rates.

3. Inadequate Focus - In the race for productive operations, organizations tend to place an emphasis on response, rather than prevention. Building risk management into your processes from the beginning can help reverse that trend and lead to positive impacts to the corporate culture.

4. Ineffective Communications - In many cases, information is spread throughout the organization, with different departments having a piece of the puzzle. As an organization grows, this problem becomes worse. An effective risk assessment/management system reduces barriers to communication and improves communication systems.

As we mentioned in our previous post on preventative maintenance programs, the vast majority of catastrophic incidents are not the result of a single factor. Time and again, however, a lack of effective communication appears as a root cause.

Specifically, a lack of communication with respect to policy, procedures, process or instructions can result in ill-informed employees and a failure to identify hazards. How can an organization manage this communication process with respect to proposed changes within the organization? One way is to develop and implement an effective Management of Change program.

Management of Change (MOC) is defined as a process used to prevent an incident or loss by identifying, assessing, managing, documenting, and communicating proposed changes prior to implementing them. The complex nature of MOC causes many companies to struggle with implementing an effective system. Often, existing MOC is accomplished using a manual system of spreadsheets which result in increased costs, time delays and lack of visibility.

One common obstacle to an effective MOC program is the tendency to route all information or all changes through an MOC program. This is not necessary and often is detrimental. Develop the MOC program so that only necessary information moves through the process. Typically, MOC is NOT required when the change is like for like or kind for kind.

That being said, let’s turn our attention to program structure. There are six basic steps to an effective Management of Change program:

1. Initiation - During this stage, the requested changes are documented with related details and submitted to the appropriate parties for the advancement of the project.

2. Impact Analysis - Impact analysis determines how the proposed changes will affect operations, as well as similar processes.

3. Approval - During this stage, the appropriate parties approve the proposed changes and modifications.

4. Execution - During execution, the program will communicate the change, verify the tasks, and integrate with customer requirements.

5. Review - Review is an after-action evaluation to determine effectiveness and lessons learned, as well as a transfer of knowledge.

6. Closure - A well-documented Management of Change (MOC) program can be used to demonstrate an organization’s commitment to due diligence in risk mitigation efforts. By effectively implementing and communicating proposed changes, you ensure a safer, more informed and more efficient work environment that reduces liability and prevents incidents.